Well, they need either old cold equity OR old cold debt (not actually both) as long as it makes up 51 percent of the new company. Alot of Lehman debt changed hands after the chap 11 filing, so you are right.....if it happens it definitely won't be because they "like" us LOL it will be because we are one of their best options to get what they want.
Plus don't forget that any Cancelation of Debt (COD) the NOLS have to be reduced by the same $ amount. There are over $ 15 B in Subordinated Notes - including the CTS.
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